NC0024252_Inspection_20191003

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Mr. Evan Rubins
Pretreatment Coordinator
City of Conover
Post Office Box 549
Conover, North Carolina 28613
Dear Mr. Rubins:
NORTH CAROLINA
Environmental Quality
3 October 2019
Subject: Pretreatment Audit Inspection
City of Conover
NPDES Permit No. NCO024252
Catawba County
Enclosed is a copy of the Pretreatment Audit Inspection Report for the inspection of the City of Conover's
approved Industrial Pretreatment Program on September 12, 2019, by Mr. Wes Bell of this Office.
The report should be self-explanatory; however, should you have any questions concerning this report, please do
not hesitate to contact Mr. Bell at [phone] or at wes.bell(&ncdenr.gov.
Sincerely,
DocuSigned by:
A14CC681 AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure:
Inspection Report
D Q
� North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
NORTH CAROLINA
Da"MoM a enWmn�bl mwnq 704,663.1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Background Information:
1. Control Authority (POTW) Name: City of Conover
2. Control Authority Representative(s): Evan Rubins
3. Title(s): Pretreatment Coordinator
4. Address of POTW:
Street/Post Office Box Post Office Box 549
City/State/Zip Code Conover, NC 28613-0549
Phone Number: [phone] Fax Number: 828-466-5299 E-Mail: [e-mail]
5. Audit Date: 09/12/2019
6. Last Inspection Date: 07/27/2017 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ® Yes ❑ No
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ❑ Yes ® No
If Yes, Explain.
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA
Parameters Covered Under Order
PCS (WENDB)Codine:
Main Program Permit Number MM/DD/YY
NCO024252 09/12/19
1-0:..-Current Number of Significant Industrial Users(SIUS)?.............................................................................................................................
2
-SIUS...
11:. Current Number of Categorical Industrial Users (CIUS)?
2
. C1US
12. Number of SIUs Not Inspected by POTW in. Last Calendar Year?
....................................................................................................................................................
0
..........................
13. Number of SIUs Not Sampled by POTW in Last Calendar Year?
.....................................................................................................................................................
0
..........................
...4:..-Enter H..her.Number of 12..°r..1.3............................................................................................................................................................................................
0
......NOIN.
1-5:..-Number of SIUs with No IUP,-or with an Expired IUP.................................................................................................................................
0
-NOCM
16. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of Last 2
2
PSNC
Semi -Annual Periods (Total Number of SIUs in SNC)
.....................................................................................................................................................................................................................................................................................................
..........................
17. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods
0
MSNC
18. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods
2
SNPS
19. Number of SIUs in SNC for Both Reporting and Limits Violations During Either of Last 2
0
Semi -Annual Periods
20. Number of SIUs in SNC for Self -Monitoring Reauirements that were Not Inspected or Sampled
0
SNIN
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 1

21. PRETREATMENT PROGRAM ELEMENTS REVIEW
Program Element:
NCO020401
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
NA
❑ Yes ❑ No
NA
❑ Yes ❑ No
NA
Industrial Waste Survey (IWS)
1/24/18
® Yes ❑ No
3/9/18
® Yes ❑ No
10/1/22
Sewer Use Ordinance (SUO)
1/15/13
® Yes ❑ No
4/2/13
® Yes ❑ No
Enforcement Response Plan (ERP)
7/2/15
® Yes ❑ No
8/19/15
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
NA
❑ Yes ❑ No
NA
❑ Yes ❑ No
Legal Authority (Sewer Use Ordinance-SUO)
22. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
® Yes ❑ No If yes, Please list these towns and/or areas. Hickory (residential).
23. If yes to #22, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ® Yes ❑ No ❑ NA
A copy, if not already submitted, should be sent to Division.
24. If yes to #22, Have you had any trouble working with these towns or districts? ❑ Yes ® No ❑ NA
If yes, Explain.
25. Date of Last SUO Adoption by Local Council 7/2/13
26. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
27. Did you send a copy of the ERP to your industries? ® Yes ❑ No
If no, POTW must send copy within 30 days.
28. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc?
❑ Yes ® No If yes, Explain.
29. List Industries under a Schedule or Order and Type of Schedule or Order
None
Resources
30. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
®S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
®S ❑M ❑U
Emergencies
Access to Operable Sampling
Equipment
❑S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
®S ❑M ❑U
Reference Materials
®S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
®S ❑M ❑U
Computer Equipment (Hardware and
Software)
®S ❑M ❑U
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 2

31. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Excel Spreadsheets.
32. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain. The SIUs are directly billed
(by contract laboratory) for laboratory and sampling costs.
Public Perception/ Participation:
33. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes ® No If yes, Explain.
34. Has any one from the public ever requested to review pretreatment program files? ❑ Yes ® No
If yes, Explain procedure. If no, How would the request be addressed? The written request would be made at City Hall and files
would be reviewed at WWTP.
35. Has any industry ever requested that certain information remain confidential from the public? ❑ Yes ® No If yes, Explain
procedure for determining whether information qualified for confidential status, as well as procedure for keeping files confidential
from public. If no. how would the request be addressed? The request would be evaluated by the Public Works Director, Public
Utilities Director and Pretreatment Coordinator. Any confidential files would be kept in a locked cabinet/office.
36. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
37. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
38. Were all industries in SNC published in the last notice? ❑ Yes ❑ No ®NA
Permitting (Industrial Waste Survey-IWS):
39a... How does the POTW become aware of new or changed Users? General information (known as the Green Form)
regarding new industrial users would be passed from City Hall/Planning Department to the Pretreatment Program
staff. An IWS form would be sent to the industrial user if needed.
39b. Once the POTW becomes aware of new or changed Users, how does the POTW determine which industries have the
reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an
SIU?) IWS Long Form information, NPDES POCs, categorical processes and volume of the process wastewater
being discharged.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
®Yes ❑No If Yes, How many are there? 1
Please list each site and how it is permitted, if applicable. Jackson Lea (groundwater remediation)
41. Does the POTW accept waste by (mark if applicable) ❑ Truck ❑Dedicated Pipe ® NA
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) No trucked waste and/or septage accepted.
43. How does the POTW allocate its loading to industries? Mark all that apply
❑ Uniform Limits ® Historical Industry Need ❑ By Surcharge ® Categorical Limits ❑ Other
Explain Other:
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? ❑ Yes ❑ No
If yes, What parameters are over allocated? Both SIUs discharge to the City of Newton, no over allocations.
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
N/A
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ❑ Yes ❑ No
If yes, what percentage of each parameter? N/A
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 3

48. How does the POTW decide on which pollutants to limit in the permits? Monitor for? (for example: were only those pollutants
listed on the application limited; categorical parameters; NPDES Pollutants of Concern) Categorical parameters, NPDES POCs,
SUO parameters
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
New SIUs — monthly monitoring with daily flow and pH for one year and potential for a reduction of monitoring based on
results; Active SIUs — quarterly monitoring minimum.
Permit Compliance:
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes ® No
If yes, which industries? What was (will be) the outcome of the adjudication?
51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporting
requirements, and permit conditions, as well as for SNC. Compliance Judgement Worksheet - SNC determinations; violations
(limit, monitoring, reporting, etc.) based on approved ERP.
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
If no, does the POTW form include all DWQ data? ❑ Yes ❑ No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ® Yes ❑ No
If no, Explain.
54. What criteria are used to determine if a slug/spill control plan is needed?
All SIUs are required to develop and submit a slug/spill control plan.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Contact information required to be updated, personnel listing and appropriate agencies for emergency notification,
authorized personnel to stop production/discharge, containment structures are in place.
56. How does the POTW decide where the sample point for an SIU should be located?
Representative of the process wastewater discharge and segregated from the domestic flow.
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly)
POTW: ® Yes ❑ No SIU: ® Yes ❑ No If yes, Explain. SOP/manuals for sampling procedures (POTW
and SIU)
58.Who performs sample analysis for the POTW for Metals Water Tech Labs, R&A Laboratories
Conventional Parameters Water Tech Labs
Organics - Water Tech Labs, R&A Laboratories
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
POTW and SIUs both use contracted laboratory's COC.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA): Not Applicable
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ❑ YES ❑ NO
60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ❑ YES ❑ NO
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ❑ YES ❑ NO Is Table Adequate? ❑ YES ❑ NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ❑ YES ❑ NO DWQ Inspector, verify yourself.
60e. If NO to any above, list violations
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ❑ NO
If yes, which ones? Eliminated: Added:
61. Do you complete your own headworks analysis (HWA) ? ❑ Yes ❑ No
If no, Who completes your HWA?
62. Do you have plans to revise your HWA in the near future? ❑ Yes ❑ No
If yes, What is the reason for the revision? (mark all that apply) ❑Increased average flow ❑NPDES limits change
❑More LTMP data available ❑Resolve over allocation 05 year expiration ❑Other, explain.
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 4

63. In general, what is the most limiting criteria of your HWA?
❑Inhibition ❑ Pass Through ❑Sludge Quality
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ❑ No
Explain. N/A - the wastewater from both SIUs is conveyed to the City of Newton's WWTP.
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW:
66. User Name
1. Hickory Springs
2. Engineered Controls
3
67. IUP Number
101HS
101J
68. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ No
❑ Yes
❑ No
69. Permit Expiration Date
11/13/22
5/1/23
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433.17
433.17
71. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
® Yes ❑ No
❑ Yes ❑ No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year?
® Yes ❑ No
® Yes ❑
No
❑ Yes
❑ No
73. a. Does File Contain Slug/Spill Control Plan?
a. EYes ❑No
a. ®Yes ❑No
a. ❑Yes ❑No
b. If No, is One Needed? See Inspection Form from POTW
b. []Yes []No
b. ❑Yes ❑No
b. []Yes❑No 11
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
®Yes❑No❑N/A
SYes❑No❑N/A
❑Yes❑No❑N/A
Organic Management Plan (TOMP)?
75. a. Does File Contain Original Permit Review Letter from Division?
a. EYes ❑No
a. EYes ❑No
a. ❑Yes ❑No
b. All Issues Resolved?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
® Yes ❑
® Yes ❑ No
❑ Yes El No
Sampling as Required b IUP, includingFlow?
!11
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
® Yes ❑ No
❑ Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
SYes❑No❑N/A
SYes❑No❑N/A
❑Yes❑No❑N/A
Sampling as Required by IUP, including Flow?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
SYes❑No❑N/A
SYes❑No❑N/A
❑Yes❑No❑N/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoSN/A
❑Yes❑NoSN/A
❑Yes❑No❑N/A
file include process/dilution flows as Required b IUP?
80b. For categorical IUs with Production based limits, does file include
❑Yes❑NoSN/A
❑Yes❑NoSN/A
❑Yes❑No❑N/A
production rates and/or flows as Required by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
7MEDes❑N/A
SYes❑No❑N/A
❑Yes❑No❑N/A
Limits Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑NoSN/A
❑Yes❑NoSN/A
❑Yes❑No❑N/A
Re ortin Non -Compliance from SIU Sampling?
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑No®N/A
a.®Yes❑No❑N/A
a.❑Yes❑No❑N/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
b•❑Yes❑No®N/A
b.®Yes❑No❑N/A
b.❑Yes❑No❑N/A
c. If applicable, did POTW resample and obtain results within 30 days of
becoming aware of SIU limit violations in the POTW's sampling of SIU?
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
c.❑Yes❑No❑N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
I
❑ Yes
®No
11
® Yes
❑
No
❑ Yes
❑ No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
❑Yes❑NoSN/A
SYes❑No❑N/A
❑Yes❑No❑N/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
01690
1 OYesONoON/All
❑Yes❑NoSN/A
❑Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑NoSN/A
❑Yes❑NoSN/A
❑Yes❑No❑N/A
88. a. Does File Contain Any Current Enforcement Orders?
a.❑Yes❑No®N/A
a.❑Yes❑No®N/A
a.❑Yes❑No❑N/A
b. Is SIU in Compliance with Order?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
❑ Yes ®No
ElYes ®No
ElYes El No
Information For You?
11
FILE REVIEW COMMENTS:
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 5

1. Both SIUs are under the control of the City of Conover; however, their discharges go to the City of Newton. The City of Newton
determines the appropriate limits based on the Newton HWA, available allocation, and NPDES and land application concerns. Conover
provides copies of all pretreatment related materials to Newton.
16/18. Hickory Springs was in SNC during second half of 2018 for nickel TRC violations and Engineering Controls was in SNC during
first half of 2019 due to chromium TRC violations.
72. SLUs were inspected by the POTW on 10/16/18 (Hickory Springs) and 11/28/18 (Engineered Controls).
78. Hickory Springs contracts Blue Ridge Environmental and Engineered Controls contracts Pace Analytical Services to perform
analyses.
81/85. The City issued NOVs to Engineered Controls for chromium violations (daily maximum and monthly average) that were
reported in February and March 2019.
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspection type Inspector Facility Type
❑N N I C 10 10 12 14 12 109 12 19 0 20
(DTIA) (TYPI) (INSP) (FACC)
1. Industry Inspected: Hickory Springs
2. Industry Address: 1115 Farrington Street
3. Type of Industry/Product: Metal Finisher/Steel Wire
4. Industry Contact: Tim Mathis Title: Maintenance Supervisor Phone: [phone]x4738 Fax: [phone]
5. Does the POTW Use the Division Model Inspection Form or Equivalent? ® Yes ❑ No
6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview
® Yes
❑ No
B. Plant Tour
® Yes
❑ No
C. Pretreatment Tour
® Yes
❑ No
D. Sampling Review
® Yes
❑ No
E. Exit Interview
® Yes
❑ No
Industrial Inspection Comments:
The manufacturing facility has approximately 80 employees and operates twenty-four hours per day, seven days per week (2 — 12 hr.
shifts and 2 — 8 hr. shifts). The facility currently produces approximately eleven million pounds per month of steel wire. The
pretreatment facility includes the following: sump pit, holding tank, pH adjustment, chemical precipitation, clarification, effluent
holding tank, in line filters, and flow measurement. The flow meter is calibrated annually by Clearwater, Inc. Wastewater solids are
dewatered (filter press) and disposed at the Catawba County Landfill by Republic Services. VLS has been contracted to
remove/dispose of any sludge in the dipping tanks (phosphate, borax, hot rinse, etc.) and HazMat removes/disposes of all used oil. The
facility has one operator per shift to oversee the operations of the pretreatment system.
The facility's records were organized and well maintained.
SUMMARY AND COMMENTS:
The City must ensure of the following:
-All chain of custody forms are completed properly (sampling times, sample types, etc.);
-The contracted labs (SIU and City) comply with the IUP required detection levels (zinc/cyanide — Pace Analytical
Services/Engineered Controls sampling and zinc — Water Tech Labs/R&A Labs/City sampling);
-The monthly average Compliance Judgement Worksheet for chromium (Engineered Controls) is corrected to show one
compliance judgement point per month and not one point per sampling event (this will increase the TRC violation percentage)
The City's records were organized and well maintained. Overall, the City's Industrial Pretreatment Program was being properly
implemented.
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 6

NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
E�`,,96DWCC3437
uSiiggnedd by:
24-AUDIT COMPLETED BY: ... DATE: 10/3/2019
Wes Bell, Environmental Specialist II
Doccu/Signed by:
AUDIT REVIEWED BY: A14CC681AF27425... DATE: 10/3/2019
W. Corey Basinger, Regional Supervisor
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 7